Privacy Policy

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1. DATA PROCESSED 

J. A. Neale provide a range of services to businesses and personal clients. The firm aims to process data, whether personal or not, only to the extent necessary to provide satisfactory data to comply with 

This privacy policy is in response to the UK General Data Protection Regulation (UK GDPR). This is designed to harmonise privacy laws, the UK GDPR refines the transparency rules for how companies describe their data processing. 

1.1 REGULATED FIRM UNDER MLR 2017 

J. A. Neale provides services that fall within one or more of the definitions of categories of services which are regulated services within the definitions under Regulation 11 and 12 of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) (“the regulations”) as enacted on the 26/06/2017 and as subsequently amended. The Money Laundering and Terrorist Financing (Amendment) Regulations 2019 enacted on 10 January 2020 and The Money Laundering and Transfer of Funds (Information) (Amendment) (EU Exit) Regulations 2019 enacted on the day of the UK left the EU. 

The law requires us to tell you about your rights and our obligations to you regarding the processing and control of your personal data. We do this now, by requesting that you read the information provided at: 

2017 s: http://www.legislation.gov.uk/uksi/2017/692/made
2020 ate: http://www.legislation.gov.uk/uksi/2019/1511/contents/made 2020 exit: http://www.legislation.gov.uk/uksi/2019/253/contents/made 

1.2 PERSONAL IDENTIFICATION 

If you are a personal client, personal data that we process may include contact information, information about your business activities and financial information such as that relating to your source of income, expenses, taxation, date of birth and photo driving licence or passport. 

In most cases, your personal data will have been provided to J. A. Neale by you. However, with your consent, we will obtain your personal data from a third-party source to confirm your identification for anti-money laundering compliance. We will us this source for ongoing monitoring of the validity of this data. We will check for any discrepancies in the information obtained and the information that you have supplied. 

Digital confirmation of identity, maybe required in the event of social distancing procedures or laws. In the event of such use of identification, a Zoom video will be used and recorded of you holding your photo identification up to the screen in order for filing a certified copy of this identification. In addition, an authorisation code will be sent to your home address, as shown on your council tax bill and/or driving licence, to complete the approval of your identity. 

1.3 THIRD PARTIES CONNECTED TO CLIENTS AND SUPPLIERS 

J. A. Neale may process your personal data if you have a personal or business connection with any of our future clients or suppliers. For example, you may be a family member, business partner, other adviser, supplier or transaction counterparty. 

The data processed may include contact information, information about business activities, information about partners, directors, employees, information relating to employment remuneration, payroll, and financial information such as that relating to income, expenses, taxation and investments. 

We may be given your personal data by our clients or suppliers, or by third parties acting on the instructions of a client or a supplier. 

We ask our clients and suppliers to bring this privacy notice to your attention as soon as they become aware that we process your personal data. 

1.4 SUPPLIERS 

If you supply J. A. Neale with goods or services, including subcontracted services that we supply to our clients, then personal data that we may process may include contact information, information about your business activities and information such as your date of birth and photo driving licence or passport. 

In most cases, your personal data will have been provided by you. However, with your consent, we will obtain your personal data from a third-party source to confirm your identification for anti-money laundering compliance, as I am required to by law under my governing body. 

regulations under the UK anti-money laundering regime. Also, to provide 

information to accountants and payroll administrators for the sole purpose of assisting their agreed services to you. 

2. THE BASES ON WHICH J. A. NEALE PROCESS PERSONAL INFORMATION 

The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category. 

If a basis on which we process your personal information is no longer relevant, then we shall immediately stop processing your data.

If the basis changes, then if required by law, we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information. 

3. INFORMATION PROCESSED UNDER CONTRACTURAL OBLIGATION 

J. A. Neale may process personal information when a contract has been formed with our business and processing is necessary to carry out our obligations under that contract, or when processing personal data is necessary in order to form a contract. 

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract. 

4. INFOROMATION PROCESSED WITH YOUR CONSENT 

Only when you have given us explicit permission to do so, do we process your personal information under the basis of consent. 

For example, you might have agreed that we may pass your name and contact information to selected associates whom we consider may provide services or products you would find useful. 

We continue to process your information on this basis until you withdraw your consent, or it can be reasonably assumed that your consent no longer exists. 

You may withdraw your consent at any time by instructing J. A. Neale at contactus@janeale.co.uk. .

We will contact you by phone, by email, text or other digital contact and in person, for all business communication whilst under agreed contract of engagement until the disengagement of contract has been made in writing via email or paper copy by either you, your business representative or J. A. Neale 

Where necessary, J. A. Neale will have meetings with you over Zoom video calling, to keep in touch from a distance if and when required, any recording of these meetings will be discussed with you at the time, for your consent and only done so for a recall of meeting minutes and safely stored with Dropbox online storage. 

5. INFOROMATION PROCESSED FOR THE PURPOSE OF LEGITIMATE INTERESTS 

We may process information on the basis there is a legitimate interest, either to you or to J. A. Neale. Where we process your information on this basis, we do after having considered: 

• Whether the same objective could be achieved through other means
• Whether processing (ornotprocessing) might cause you harm
• Whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so 

For example, we may process your data on this basis for the purposes of:

• Record-keeping for the required and necessary administration of our business
• Responding to communication from you to which webelieve you would expect a response
• Protecting and asserting the legal rights of anyparty
• Insuring against orobtaining professional advice that is required to manage business risk
• Protecting your interests where we believe we have a duty to do so 

6. INFOROMATION PROCESSED DUE TO LEGAL OBLIGATIONS 

We must process your information in order to comply with a statutory obligation. For example, we may be required to give information to legal or tax authorities if they so request or if they have the proper authorisation such as a search warrant or court order. This may include your personal information. We must check your information we hold and monitor the accuracy, updating any changes periodically. 

7. SPECIFIC USES OF INFORMATION PROVED BY YOU 

7.1 COMMUNICATING WITH YOU 

When you contact J. A. Neale, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need. We record your request and our reply in order to increase the efficiency of our business. We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service. 

7.1 DEALING WITH COMPLIAINTS 

When we receive a complaint, we record all the information you have provided. We use that information to resolve your complaint. If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is. 

If the complaint relates to information on our website and we feel it is justified or if we believe the law requires us to do so, we shall remove the information while we investigate. If we think your complaint is vexatious or without any basis, we shall not correspond with you about it. We may compile statistics from information relating to complaints to assess the level of service we provide, but not in a way that could identify you or any other person. 

8. RECORDING AND SECURITY OF PERSONAL INFORMATION 

We use anti-money laundering compliancy software to process identity checks and risk assessments of all clients that we engage with, the software that we use is SmartSearch, Xama and Senta. This software is used to confirm your identity. 

All information received from both online software services are stored securely online with the providers and a pdf copy is stored on our Dropbox customer file for the purpose of an investigation of our business policies and procedures. 

We are under the governing body of The Association of Accounting Technicians (AAT) and I have to supply examples of client procedures annually to apply for our practicing certificate. If we are a mandatory on your business bank account, we may use the front page of one the statements to prove official evidence of this to the AAT in my application. WE may also send them a copy of our letter of engagement for the same purpose. 

We process this data based on consent for purposes that include:
 

• The compliancy of our membership with our governing body(AAT)
• Managing and developing our business or services
• Analysing the risk factors of our engagement for our business 

We do not sell any personal data to third parties. 

9. USE OF INFORMATION COLLECTED VIA AUTOMATED SYSTEMS WHEN VISITING OUR WEBSITE 

9.1 COOKIES 

Cookies are small text files that are placed on your computer's hard drive by web browsers when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved. 

Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely. Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use. 

9.2 PERSONAL IDENTIFIERS FROM YOUR BROWSING ACTIVITY 

Requests by your web browser to our server for web pages and other content on my website are recorded. We record information that could identify your location, such as your IP address. We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website. However, our policy is not to use such data for the purpose of personal identification. 

10. DISCLOSURE AND SHARING YOUR INFORAMTION 

10.1 ACCES TO YOUR OWN INFORMATION 

The only sharing of your information will be between myself any payroll administrator and your accountant, to achieve completion of the service we are paid to supply you with. 

10.2 ACCESS TO YOUR PERSONAL INFORMATION 

• At any time, you may review or update personally identifiable information that we hold about you.
   
• To obtain a copy of any information that is not provided through my website you may send me a request to contactus@janeale.co.uk
   
• After receiving the request, we will tell you when we expect to provide you with the information. 

10.3 REMOVAL OF YOUR INFORMATION 

If you wish me to remove personally identifiable information, you may contact me at contactus@janeale.co.uk 

10.4 VERIFICATION OF YOUR INFORMATION 

When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information. 

10.5 RETENTION PERIOD FOR PERSONAL DATA 

Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us: 

• To provide you with the services you have requested;
   
• To comply with other law, including for the period demanded by our tax authorities
   
• To support a claim or defence in court
   

11. OTHER MATTERS 

11.1 IF YOU ARE NOT HAPPY WITH OUR PRIVACY POLICY 

• If you are not happy with our privacy policy or if you have any complaint, then you should tell us.
   
• If a dispute is not settled, then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of
  mediation or arbitration.
   
• If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the
  Information Commissioner's Office. This can be done at https://ico.org.uk/concerns/
   

11.2 COMPLIANCE WITH THE LAW 

Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you. 

11.3 REVIEW OF THIS PRIVACY POLICY 

We may update this privacy notice from time to time as necessary. We may supply you with a secure online folder or access to a client portal via Dropbox as part of our business service to you. This folder will hold our most recent and up to date firm policies for you to view at any time. Please see my website wwww.janeale.co.uk for all policy updates also. 

If you have any questions regarding our privacy policy, please contact us. 

Jenny Neale AATQB
J. A. Neale
St Andrews Castle
33 St Andrews Street South 

Bury St Edmunds IP33 3PH 

Tel: 07566 207786 

Email: contactus@janeale.co.uk